Group Financing: From Thin Capitalization to Interest Deduction Limitation Rules
- K. von Brocke; E. Garcia Perez
- International Transfer Pricing Journal, 2009 (Volume 16), No 1
- 1 January 2009
This article discusses the evolution of thin capitalization rules in Germany and the European Union. Topics addressed include jurisprudence of the European Court of Justice; past and present German rules on the tax treatment of interest expense, including the new interest deduction limitation rules; and criticism to date of the new German rules.